On 15 September 2026, the Dutch government published the full Tax Plan 2027 package. For business owners, the picture is mixed: the published 2027 parameters leave the corporate income tax and Box 2 rates broadly unchanged, while introducing targeted measures for innovation, individual entrepreneurs, employers, property and borrowing from one’s own company. For private investment wealth, the main issue remains the uncertainty surrounding the future of Box 3.
The Tax Plan 2027 and related tax bills were submitted to the Dutch House of Representatives on Budget Day. They are therefore proposals, not final legislation. The House of Representatives and Senate may still amend them. Most measures are intended to take effect on 1 January 2027 unless stated otherwise.
For Dutch private limited companies (BVs), the central point is that the 2027 key table retains a corporate income tax rate of 19% on the first €200,000 of taxable profit and 25.8% on the excess. The innovation box rate remains 9%. The published package therefore contains no general increase in Dutch corporate income tax rates. That does not mean there are no changes for companies. The package includes several technical and targeted measures. For innovative SMEs in particular, the proposed expansion of the simplified innovation box calculation is noteworthy.
Innovation box: simplified cap rises from €25,000 to €100,000
The simplified innovation box regime is designed to make the innovation box more accessible where a detailed allocation of benefits to individual intangible assets would be disproportionately burdensome. Under the current simplified method, 25% of profit can be treated as innovation box profit, capped at €25,000. The government proposes to increase that annual cap to €100,000 from 1 January 2027.
For innovative SMEs, this may improve the balance between the tax benefit and the administrative work involved. The other qualifying conditions for the innovation box continue to apply; the higher cap does not mean that every innovative BV automatically receives the 9% rate on €100,000.
Participation exemption and reorganisations
The package also contains technical amendments concerning foreign-exchange results and the Dutch participation exemption. These may matter to internationally active groups that hedge currency risks on qualifying participations. In addition, the presumption of non-business purpose in the business merger and demerger facilities is to be removed following a Dutch Supreme Court judgment, shifting the burden of proof in certain restructuring cases back to the tax inspector.
For director-major shareholders (directeur-grootaandeelhouders, or DGAs), the 2027 fiscal key table shows a Box 2 rate of 24.5% on taxable substantial-shareholding income up to €69,607 and 31% on the excess. The rates themselves therefore remain unchanged under the published parameters. The threshold is, however, affected by the government’s proposed limited inflation indexation for 2027.
For dividend planning, the interaction between corporate income tax and Box 2 remains the key consideration. Whether profits should remain in the BV, be distributed as dividends or be invested privately depends not only on headline rates, but also on expected returns, liquidity needs, investment horizon and the shareholder’s Box 3 position. There is no single answer that works for every DGA.
Excessive borrowing from one’s own BV: no new general threshold, but an inheritance adjustment
The excessive borrowing rules remain important. The explanatory memorandum refers to the €500,000 maximum applicable in 2026. The new proposal does not generally change that threshold. Instead, it addresses a specific interaction with the relief for inherited substantial shareholdings.
From 1 January 2027, a deemed regular benefit arising under the excessive borrowing rules would be excluded from that inheritance relief. This is particularly relevant where an estate includes both a substantial shareholding in a BV and a debt owed to that BV. For most DGAs this is not a new annual charge, but it can be material in estate and succession planning.
Company migration to the Netherlands
Where a company’s place of effective management moves to the Netherlands, the government proposes that the acquisition cost of a substantial shareholding should generally be set at fair market value at that time. The aim is to bring only subsequent gains or losses wit
Box 3 is highly relevant to business owners who hold investments, cash, a second home or other taxable assets privately. Legally, Box 3 is a tax on income from savings and investments rather than a standalone net wealth tax, although it is often loosely referred to as a “wealth tax”. For 2027, the fiscal key table shows a Box 3 tax rate of 36% and a tax-free allowance of €60,098 per taxpayer. The proposed limitation of inflation indexation also affects the tax-free allowance. The 36% tax rate itself remains unchanged.
Counter-evidence remains relevant
Until a new Box 3 system takes effect, the current system based on deemed returns remains relevant. Under the statutory counter-evidence mechanism, taxpayers may report their actual return if it is lower than the deemed return. The Dutch Tax Administration then uses the more favourable amount. Investors and owners of rental or second properties should therefore continue to keep clear records of income, value movements and relevant interest on Box 3 debts.
The proposed 2028 Box 3 system is not yet final
The government still aims to introduce a system based on actual investment returns from 1 January 2028. The House of Representatives passed the Actual Return Box 3 Bill in February 2026, but on 30 June 2026 the Senate postponed the final vote pending an announced amending bill (novelle). No separate Box 3 novelle is listed in the Tax Plan package published on 15 September.
For entrepreneurs with substantial private investment wealth, the practical conclusion is that the 2028 end-state is not yet settled. Irreversible transfers of wealth between private ownership and a BV should not be based solely on assumptions about the future Box 3 regime while the parliamentary process is still continuing.
For entrepreneurs taxed in personal income tax rather than through a BV, the changes are more direct. The self-employed deduction is scheduled to fall from €1,200 in 2026 to €900 in 2027. The SME profit exemption remains 12.7%. The start-up deduction is reduced much more sharply. The government proposes to cut it from €2,123 to €10 on 1 January 2027 and abolish it from 1 January 2028. There is no grandfathering for entrepreneurs who started before 2027. The special accelerated depreciation scheme for starters is also intended to end in 2028, while the start-up deduction for disabled entrepreneurs is proposed to end in 2029.
Energy Investment Allowance rises to 45.5%
On the positive side for qualifying investment, the Energy Investment Allowance (Energie-investeringsaftrek, EIA) is proposed to rise from 40% to 45.5% from 1 January 2027. For businesses already planning investments in energy efficiency or renewable energy, timing may therefore matter. The usual qualification requirements, including inclusion on the Energy List, remain decisive.
A separate bill introduces more favourable tax treatment for employee share options granted by qualifying start-ups and scale-ups. The core proposal is a 35% reduction in the taxable base, so only 65% of the relevant benefit is subject to wage tax. At the top Box 1 rate of 49.5%, this is equivalent to an effective tax burden of approximately 32.17% of the full benefit, provided all conditions are met.
Taxation would in principle also be deferred until the shares obtained under the options are sold, better aligning the tax charge with a liquidity event. The scheme is subject to qualifying conditions and state-aid rules. The Dutch Tax Administration considers implementation technically possible from 1 January 2027, but formal commencement is tied to a date to be set by Royal Decree. Transitional rules are proposed for options granted on or after 17 April 2025 that have not yet left the wage-tax sphere by the end of 2026.
To help fund the measure, the co-working spouse deduction and the business cessation deduction are to be reduced by 75% first and abolished three years later. Their timing follows the formal commencement of the new share-option regime.
For employers, a material budgetary measure is the planned increase in the contribution to the Dutch Disability Fund (Arbeidsongeschiktheidsfonds, Aof). The government attributes €1.5 billion of additional business revenue to this measure in 2027, rising to €1.7 billion on a structural basis from 2028. The exact contribution percentage is not set in the Tax Plan; it will be determined separately in the annual regulation on social insurance contribution rates.
The government also proposes to abolish the targeted exemption for discounts on an employer’s own products or services. At present, qualifying discounts of up to 20% of fair market value, capped at €500 per employee per year, can be specifically exempt. Once abolished, employers may - subject to the relevant conditions - use the discretionary scope of the work-related costs scheme or treat the benefit as taxable pay. The tax-free mileage allowance is to be legislated at €0.25 per kilometre instead of €0.23, with retroactive effect from 1 January 2026. For 2027, €0.25 is therefore the relevant proposed statutory amount.
The previously legislated jump in the age threshold for the Dutch youngtimer company-car regime to 25 years in 2027 is to be softened. The government now proposes a 17-year threshold for 2027 and a structural 20-year threshold from 2028. The additional 2027 transitional protection is subject, among other things, to the car already having been made available to the relevant entrepreneur or employee by 31 December 2025. From 2028, the 20-year threshold applies to all cars. This can be particularly relevant to DGAs, employees and individual entrepreneurs who deliberately use older company cars. A car acquired or first made available in 2027 should not automatically be assumed to qualify for the transitional protection.
For residential property that the purchaser will not use as their main residence - for example, a second home or buy-to-let property - the government proposes to reduce the general residential transfer tax rate from 8% to 7% from 1 January 2027. The general rate for non-residential property remains 10.4% in the 2027 key table. For property investors and BVs acquiring residential property, this can reduce transaction costs on 2027 purchases. The subsequent Box 3 or corporate income tax treatment of investment returns is a separate issue and should be assessed independently.
For BVs and DGAs, Tax Plan 2027 does not introduce a broad increase in corporate income tax or Box 2 rates, but it does contain a series of measures that can be significant in specific circumstances. Individual entrepreneurs face more visible reductions in business deductions. At the same time, qualifying energy investment and - subject to conditions - employee participation in start-ups and scale-ups are being encouraged through targeted tax measures.
For business owners with significant private wealth, Box 3 remains the area with the greatest uncertainty. The 2027 parameters are now known, but the intended system from 2028 has not completed the parliamentary process. Good tax planning therefore requires a clear distinction between the concrete 2027 proposals and the still-evolving post-2027 framework.
Not your regular financial advisor. Unlock your financial potential
and get your money to work!
✔️ Always available for all your questions
✔️ Customized advice for your business
✔️ For long-term relationships
Suijkerbuijk+Co B.V.
Schippersgracht 3, 1011TR Amsterdam
KvK: 97096296
info@suijkerbuijk-co.nl
